G.R. No. 227268. August 28, 2019.
OFFICE OF THE OMBUDSMAN, PETITIONER, VS. PCSUPT. RAUL D. PETRASANTA, RESPONDENT.

FACTS

WERFAST Documentation Agency proposed to the PNP to establish an online renewal and courier delivery system for firearms licenses. A Memorandum of Agreement was executed in May 2011, and a Technical Working Group (TWG) was created to study the proposal, with respondent PCSUPT. Raul Petrasanta designated as its chairman. The TWG issued a memorandum favorably recommending WERFAST’s proposal. Subsequently, an FEO Courier Services Accreditation Board (FEO-CSAB) was formed, again with Petrasanta as chairman, to accredit service providers. Despite a PNP Legal Service opinion that such service should be optional and not exclusive to one provider, a policy was later approved making courier delivery mandatory.
The Office of the Ombudsman found Petrasanta administratively liable for Grave Misconduct, Serious Dishonesty, and Grave Abuse of Authority. It ruled that he gave WERFAST unwarranted benefits by fast-tracking its accreditation despite its failure to meet several mandatory requirements under the very Policy on Accreditation he was tasked to enforce, such as having an extensive nationwide network and updated BIR and LGU permits. The Court of Appeals reversed the Ombudsman’s decision, finding no substantial evidence to support the findings of administrative liability.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in reversing the Ombudsman’s finding of administrative liability against PCSUPT. Raul Petrasanta.

RULING

Yes. The Supreme Court granted the petition and reinstated the Ombudsman’s decision. The Court emphasized that a petition for certiorari under Rule 65 assailing the CA’s review of an Ombudsman decision is limited to determining whether the CA acted with grave abuse of discretion. The Court found that the CA did commit such abuse by disregarding the factual findings of the Ombudsman, which are generally accorded respect and finality when supported by substantial evidence.
The legal logic is clear: the Ombudsman’s factual conclusions, based on the evidence on record, established that Petrasanta, as chairman of both the TWG and the FEO-CSAB, played an indispensable role in a process that conferred an unwarranted benefit to WERFAST. The evidence showed WERFAST was accredited despite patent deficiencies in its application, such as lacking an extensive network and proper permits. By recommending and later accrediting WERFAST under these circumstances, Petrasanta’s actions constituted Grave Misconduct, which involves a wrongful intention coupled with a conscious disregard for established rules. The CA’s conclusion that there was no substantial evidence was a capricious and whimsical disregard of this evidentiary record, thus constituting grave abuse of discretion warranting reversal by the Supreme Court.